Division of Research

NSF Support Disclosure Requirement

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NSF Support Disclosure Requirement

The National Science Foundation (NSF) requires that all proposal submissions include a full disclosure of current and pending support from any source. Researchers must identify all sources of support, ensuring that complete and accurate information is provided.

According to the NSF Proposal and Award Policies and Procedures Guide (PAPPG), current and pending (other) support information is used to assess the capacity or any conflicts of commitment that may impact the ability of the individual to carry out the research effort as proposed. The information also helps assess any potential scientific and budgetary overlap/duplication with the project being proposed.

Current and pending (other) support information must be provided separately for each individual designated as a senior/key person through use of the Science Experts Network Curriculum Vitae (SciENcv) researcher profile system. Senior/key personnel must prepare, save, certify and submit these documents as part of their proposal via Research.gov or Grants.gov.

This document should include all resources made available, or expected to be made available, to an individual in support of the individual’s research and development efforts, regardless of:

  • whether the source is foreign or domestic;
  • whether the resource is made available through the entity applying for a research and development award or directly to the individual; or
  • whether the resource has monetary value.

Support includes in-kind contributions with an estimated dollar value greater than $5,000 requiring a commitment of time and directly supporting the individual’s research and development efforts, such as the provision of office or laboratory space, equipment, supplies, employees or students.

As part of a 2024 change in the PAPPG, consulting activities must be disclosed under the proposals and active projects section of the common form when any of the following scenarios apply:

  • The consulting activity will require the senior/key person to perform research as part of the consulting activity.
  • The consulting activity does not involve performing research, but is related to the senior/key person’s research portfolio and may have the ability to impact funding, alter time or effort commitments, or otherwise impact scientific integrity.
  • The consulting entity has provided a contract that requires the senior/key person to conceal or withhold confidential financial or other ties between the senior/key person and the entity, irrespective of the duration of the engagement.

Federal agencies such as the NSF have expressed heightened concern about the lack of disclosure of collaborations with, and/or funding by, foreign entities. This includes both foreign governments and foreign institutions of higher education. Each agency provides its own definition of what constitutes a “foreign” or “international” component.

The NSF asks for information on international activities on the cover sheet with the following instruction:

“For each proposal that describes an international activity, proposers should list the primary countries involved. An international activity is defined as research, training and/or education carried out in cooperation with international counterparts either overseas or in the U.S. using virtual technologies. Proposers also should enter the country/countries with which project participants will engage and/or travel to attend international conferences.”

NSF PAPPG: Definition of International Activities

If an organization discovers that a PI or co-PI on an active NSF grant failed to disclose current support or in-kind contribution information as part of the proposal submission process, the authorized organizational representative in either Sponsored Projects or the BioMed Research Administration must submit the following information within 30 calendar days of the identification of the undisclosed current support or in-kind contribution through use of the “Other Request” category in the Notification and Request Module in Research.gov:

  • PI/co-PI name
  • Project title
  • Award number (if available)
  • Source of support
  • Primary place of performance
  • Project start and end date
  • Total award amount (including indirect costs)
  • Brief description of the major goals of the project
  • Description of any overlap/duplication of the project with the NSF award
  • Impact on the ability of the PI/co-PI to carry out the NSF award
  • Number of person-month(s) (or partial person-months) per year committed to the project
  • Applicable year (e.g., 2023, 2024)

The post-award disclosure requirement applies to current support (including in-kind contributions) that was active as of the date the proposal was submitted to NSF. Upon receipt and review of the information provided, NSF may consult with the authorized organizational representative or designee. Based on the results of this review, the NSF will determine the impact of the new information on the NSF-funded grant and take appropriate action.

Related Resources

NSF Consulting Disclosure Guide [PDF]

The Office of Sponsored Projects has developed a flow chart to help determine whether consulting activities must be disclosed according to NSF policy.

NSF Pre-Award and Post-Award Disclosures

The NSF maintains a disclosures table that provides guidance regarding what information must be disclosed as part of a grant proposal and clarity regarding the disclosure of in-kind contributions, consulting and startup companies.

NSF System Update: RPPR

The NSF has additional requirements for the Research Performance Progress Report (RPPR), including a question on current and pending support to be answered by PIs when submitting their annual and final reports.

Setting up a SciENcv Scholarly Profile

This video walks Brown researchers through the process of setting up a profile in SciENcv, to meet the NSF requirement of submitting a Biosketch through the platform.